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Case 18-2868, Document 280, 08/09/2019, 2628232, Page63 of 74 For all these reasons, the Court should simply decline to decide the public figure issue at this juncture. But if it chooses to reach the issue, it should reject Defendant’s unsupported argument. VIII. THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,” AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE OF ITS FALSITY As a final argument, Defendant argues that her January 2015 statement was “substantially true.” Given that the statement argues that Ms. Giuffre lied when she said she was sexually trafficked by Defendant, the reader of Defendant’s motion might reasonably expect to see some evidence presented showing that Defendant was not a sex trafficker. Instead, the reader is treated to technical quibbles. For example, the lead argument to show the “substantial” truth of Defendant’s statement is the argument that Ms. Giuffre was not fifteen years old, but all of sixteen or seventeen years old when she was trafficked. As the Court knows (and can take judicial notice of), Florida law makes age eighteen the age of consent. Accordingly, it is no moment that Ms. Giuffre may have been mistaken about the exact year the sex trafficking started. Call this the “yes-I’m-a-sex-trafficker-but-only-of-sixteen-year-old-girls” defense. To even describe the defense is to show how meritless it is. More broadly, at issue are the statements Ms. Giuffre made regarding Defendant’s involvement in, and knowledge of, the sexual abuse and sex trafficking of Ms. Giuffre (and other minor girls) through a recruitment scheme executed by Defendant and Jeffrey Epstein. In response to those various statements, Defendant publicly claimed that, “the allegations made by (Ms. Giuffre) against Ghislaine Maxwell are untrue.” Defendant continued that Ms. Giuffre’s “claims are obvious lies and should be treated as such....” Defendant, through her statement 55